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r <br />CAUFORNIA <br />CALIFORNIA REGIONAL WA <br />CENTRAL VALLEY REGION <br />3443 ROUTIER ROAD <br />SACRAMENTO, CA 95827-3098 <br />6 February 1987 <br />Mr. Howard Hatayama <br />Department of Health Services <br />Toxic Substances Control Division <br />North Coast California Section <br />5850 Shellmound <br />Emeryville, CA 94608 <br />GEORGE DEUKMEJIAN. Governor" <br />(a] <br />F� <br />ICE <br />1 n , <br />TOXIC PITS CLEANUP ACT (TPCA), HIGH EXPLOSIVE HAZARDOUS LEVELS <br />The Regional Board is in the process of determining the applicability of the TPCA <br />to Lawrence Livermore National Laboratory (LLNL)bite 3 0 wase UAaAg=t units. <br />LLNL disposed of high explosive wastewaters into several lagoons until May 1985, <br />when the waste streams were diverted into Class II surface impoundments. Addi- <br />tional sampling will be required of LLNL, as the Regional Board does not have <br />adequate information to make a final determination regarding coverage of the TPCA <br />to these waste management units. The additional sampling will establish whether <br />hazardous levels of contaminants have been exceeded in the waste management units. <br />However, hazardous levels have not been established for high explosives. The <br />explosive compounds used at LLNL Site 300 are: HMX (cyclotetramethylene <br />tetranitramine), RDX (cyclo 1,3,5 trimethylene, 2,4,6, trinitramine), PETN <br />(pentaerythritol tetranitrate) and TNT (trinitrotoluene). TNT is reported not to <br />be processed using a wet stream. <br />On 3 November 1986, LLNL wrote to the Department of Energy, Environmental Safety <br />and Quality Assurance Division stating thay they had self -determined their wastes <br />to be non -hazardous under Title 22, Chapter 30, Section 66305(b) of the California <br />Administrative Code (CAC), The Department of Health Services was notified at that <br />time (enclosed). If the Department of Health Services does not concur with the <br />LLNL findings, please notify the Regional Board by 17 April 1987, so that a final <br />determination of the applicability of the TPCA to waste management units at LLNL <br />can be made. <br />Based on the information provided by LLNL, the Regional Board has no data to refute <br />their conclusions. In particular, the Regional Board will concur with their <br />self -determined non -hazardous levels with respect to high explosives. However, we <br />will be evaluting the additional sa-npling data to assure that hazardous levels have <br />not been exceeded for other contaminants. The Regional Board will notify you of <br />the additional sampling results to be performed under the TPCA. <br />